On May 15, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Investment Retrievers, Inc.,
and
Espinoza, Gabriela,
Espinoza Torres, Jorge L,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
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FILED
DALLAS COUNTY
1/9/2020 4:17 PM
FELICIA PITRE
DISTRICT CLERK
CAUSE NO. DC-19-06955
DC-l9—06955 Rosa Delacerda
INVESTMENT RETRIEVERS, INC.,
INC., §§ IN THE DISTRICT COURT OF
Plaintiff,
Plaintiff, §
§
§
§
vs.
VS. §
§
§
§
GABRIELA ESPINOZA AKA GABRIELA §
§ 298th
298th JUDICIAL DISTRICT
MARTINEZ AND JORGE L ESPINOZA §
§
TORRES AKA JORGE ESPINOZA §
§
TORRES AKA JORGE E TORRES AKA
TORRESAKAJORGEETORRESAKA §
§
JORGE ESPINOZA AKA JORGE §
§
TORRES, §
§ DALLAS COUNTY, TEXAS
DALLASCOUNTY,TEXAS
Defendant.
Defendant.
PLAINTIFF'S
PLAINTIFF’S MOTION FOR CONTINUANCE
TO THE HONORABLE JUDGE OF SAID COURT:
Plaintiff,
Plaintiff, Investment Retrievers, Inc.
Investment Retrievers, Inc. ("Plaintiff')
(“Plaintiff”) files
files this
this Motion for Continuance pursuant
for Continuance pursuant
to
to the
the Texas
Texas Rules
Rules of
of Civil
Civil Procedure
Procedure and
and would respectfully
respectfully show as
as follows:
follows:
1.
1. This
This case is currently
case is currently set
set for
for trial
trial on January
January 21, 2020.
21, 2020.
2.
2. Plaintiff
Plaintiff is
is currently
currently waiting
waiting for
for additional
additional supporting
supporting documentation
documentation from the
the original
original
creditor
creditor before
before it
it can prepare for
can prepare for trial.
trial. Plaintiff
Plaintiff has
has requested
requested such but not
such but yet received
not yet it. In
received it. In
addition, the parties
addition, the parties have
have not
not scheduled
scheduled mediation
mediation nor
nor agreed
agreed upon a
a mediator.
mediator.
3.
3. Plaintiff
Plaintiff requests
requests that the current
that the current trial
trial setting be continued
setting be continued for
for 90
90 days
days to
to allow
allow the
the parties
panics
to
to schedule
schedule mediation
mediation and
and for
for Plaintiff
Plaintiff to
to obtain
obtain additional
additional documentation
documentation for
for trial.
trial.
4.
4. Discovery will
Discovery will continue
continue if settlement is not obtained.
if settlement is not obtained.
5.
5. Plaintiff
Plaintiff would
would show that
that this
this continuance
continuance is
is not
not sought
sought for
for delay, but only
delay, but only that justice may
that justice
be done.
be done.
WHEREFORE, PREMISES CONSIDERED, Plaintiff
Plaintiff prays
prays that
that this
this Motion
Motion for
for
Continuance be granted
Continuance be granted and
and for
for such
such other
other relief
relief to
to which the Court may deem Plaintiff
the Court to be
Plaintiff to be
entitled
entitled and
and for
for which
which Plaintiff
Plaintiff will
will ever pray.
ever pray.
MOTION FOR CONTINUANCE PAGE 1
1
Respectfully submitted,
f
Carl Tucker
StateBar No. 20265 100
Law Office 0f Carl Tucker PLLC
2028 E Ben White Blvd #240—1650
Austin Texas 78741
Tel: (866)457-4107
Fax: (214) 594-7862
Attorney for the Plaintiff,
Investment Retrievers, Inc.
CERTIFICATE 0F CONFERENCE
I hereby certify that I emailed counsel for Defendant regarding this motion, but he has not
responded. Thus, the motion is being submitted to the Court for determination. '7
Carl TuckeE
CERTIFICATE 0F SERVICE
The undersigned hereby certifies that 0n the 9 day 0f January 2020, a true and correct
copy of the foregoing instrument was served on all panics and/or their counsel of record in
accordance with Rule 21a, Tex. R. Civ. P.
Carl Tucker
MOTION FOR CONTINUANCE PAGE 2
VERIFICATION
State 0f Texas
County of Harris
BEFORE ME, the undersigned authority, 0n this day personally appeared Carl Tucker,
Who swore 0n oath that the following facts are true:
1. My name is Car] Tucker.
2. I am the attorney 0f Investment Retrievers, Inc.
3. Ihave read the above and foregoing Motion for Continuance, and every statement
contained in it is Within my personal knowledge and is true and correct.
Executed this E E day of January 2020.
Carl Tucker, Affiant
State ofTexas
County of Harris
Subscribed and sworn to (or affirmed) before me on this 03 day of January 2020 by Carl Tucker,
proved to me on the basis 0f satisfactory evidence to be the person(s) who appeared before me.
ow Pug HOWARD A LOZADA PEREZ
a?
(a Notary ID #132219954
Expires
.5. p My Commission
”com? October 22, figua
VERIFICATION PAGE SOLO
Document Filed Date
January 09, 2020
Case Filing Date
May 15, 2019
Category
CNTR CNSMR COM DEBT
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FILED DALLAS COUNTY 1/9/2020 4:17 PM FELICIA PITRE DISTRICT CLERK CAUSE NO. DC-19-06955 DC-l9—06955 Rosa Delacerda INVESTMENT RETRIEVERS, INC., INC., §§ IN THE DISTRICT COURT OF Plaintiff, Plaintiff, § § § § vs. VS. § § § § GABRIELA ESPINOZA AKA GABRIELA § § 298th 298th JUDICIAL DISTRICT MARTINEZ AND JORGE L ESPINOZA § § TORRES AKA JORGE ESPINOZA § § TORRES AKA JORGE E TORRES AKA TORRESAKAJORGEETORRESAKA § § JORGE ESPINOZA AKA JORGE § § TORRES, § § DALLAS COUNTY, TEXAS DALLASCOUNTY,TEXAS Defendant. Defendant. PLAINTIFF'S PLAINTIFF’S MOTION FOR CONTINUANCE TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff, Plaintiff, Investment Retrievers, Inc. Investment Retrievers, Inc. ("Plaintiff') (“Plaintiff”) files files this this Motion for Continuance pursuant for Continuance pursuant to to the the Texas Texas Rules Rules of of Civil Civil Procedure Procedure and and would respectfully respectfully show as as follows: follows: 1. 1. This This case is currently case is currently set set for for trial trial on January January 21, 2020. 21, 2020. 2. 2. Plaintiff Plaintiff is is currently currently waiting waiting for for additional additional supporting supporting documentation documentation from the the original original creditor creditor before before it it can prepare for can prepare for trial. trial. Plaintiff Plaintiff has has requested requested such but not such but yet received not yet it. In received it. In addition, the parties addition, the parties have have not not scheduled scheduled mediation mediation nor nor agreed agreed upon a a mediator. mediator. 3. 3. Plaintiff Plaintiff requests requests that the current that the current trial trial setting be continued setting be continued for for 90 90 days days to to allow allow the the parties panics to to schedule schedule mediation mediation and and for for Plaintiff Plaintiff to to obtain obtain additional additional documentation documentation for for trial. trial. 4. 4. Discovery will Discovery will continue continue if settlement is not obtained. if settlement is not obtained. 5. 5. Plaintiff Plaintiff would would show that that this this continuance continuance is is not not sought sought for for delay, but only delay, but only that justice may that justice be done. be done. WHEREFORE, PREMISES CONSIDERED, Plaintiff Plaintiff prays prays that that this this Motion Motion for for Continuance be granted Continuance be granted and and for for such such other other relief relief to to which the Court may deem Plaintiff the Court to be Plaintiff to be entitled entitled and and for for which which Plaintiff Plaintiff will will ever pray. ever pray. MOTION FOR CONTINUANCE PAGE 1 1 Respectfully submitted, f Carl Tucker StateBar No. 20265 100 Law Office 0f Carl Tucker PLLC 2028 E Ben White Blvd #240—1650 Austin Texas 78741 Tel: (866)457-4107 Fax: (214) 594-7862 Attorney for the Plaintiff, Investment Retrievers, Inc. CERTIFICATE 0F CONFERENCE I hereby certify that I emailed counsel for Defendant regarding this motion, but he has not responded. Thus, the motion is being submitted to the Court for determination. '7 Carl TuckeE CERTIFICATE 0F SERVICE The undersigned hereby certifies that 0n the 9 day 0f January 2020, a true and correct copy of the foregoing instrument was served on all panics and/or their counsel of record in accordance with Rule 21a, Tex. R. Civ. P. Carl Tucker MOTION FOR CONTINUANCE PAGE 2 VERIFICATION State 0f Texas County of Harris BEFORE ME, the undersigned authority, 0n this day personally appeared Carl Tucker, Who swore 0n oath that the following facts are true: 1. My name is Car] Tucker. 2. I am the attorney 0f Investment Retrievers, Inc. 3. Ihave read the above and foregoing Motion for Continuance, and every statement contained in it is Within my personal knowledge and is true and correct. Executed this E E day of January 2020. Carl Tucker, Affiant State ofTexas County of Harris Subscribed and sworn to (or affirmed) before me on this 03 day of January 2020 by Carl Tucker, proved to me on the basis 0f satisfactory evidence to be the person(s) who appeared before me. ow Pug HOWARD A LOZADA PEREZ a? (a Notary ID #132219954 Expires .5. p My Commission ”com? October 22, figua VERIFICATION PAGE SOLO